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Does Tax Really Matter in Planning the Dongbu Group's Spin-Offs? (세무계획측면에서 분석한 동부그룹 물적분할)

  • Jun, Byung Wook;Cho, Hyeong Tae
    • The Journal of Small Business Innovation
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    • v.20 no.1
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    • pp.1-18
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    • 2017
  • This study examined whether divided and spun-off companies design and execute spin-offs to minimize tax burdens by analyzing multiple spin-off transactions in the Dongbu Group, when the Korean tax law regarding corporate restructuring was amended in July 2010. Before the July 2010 tax amendment, taxes on the capital gains arising from the qualifying spin-off were deferred to the earlier of the shares in or assets acquired by the spun-off company are disposed. This tax treatment relieves the divided company's tax burden by deferring taxes on capital gains, compared with non-qualifying spin-offs. However, if shares in or assets acquired by the spun-off company are disposed after the July 2010 tax amendment, the capital gain incurred at the time of the qualifying spin-off would be taxed again at the spun-off company, in addition to a taxation on the divided company's capital gains. This creates double taxation implications for the parties involved in the spin-off. As a result, the double taxation may outweigh the benefit from the tax deferral on the qualifying spin-off, which may make a qualifying spin-off tax unfavorable. Among the four spin-off cases in the Dongbu Group addressed in this study, a spin-off occurred before the tax amendment, whereas three spin-offs occurred after the tax amendment. Initially, we expected that the spin-off before the tax amendment would be a qualifying spin-off, and the other three spin-offs would be non-qualifying spin-offs, considering the taxation rules before and after the July 2010 tax amendment. However, based on the review of summarized balance sheets disclosed in the spin-offs' corporate filings, no capital gains arose during the four spin-offs that occurred in the Dongbu Group. Therefore, we concluded that the Dongbu Group considered non-tax factors more than tax factors while designing and executing the spin-offs. The local media posited during this period that these spin-offs may intend to resolve financial issues in the Dongbu Group, and this analysis was supported by the fact that some shares in the new spun-off companies were sold by the Dongbu Group. Our case studies provide evidence that all costs, including both tax and non-tax costs, must be considered in the course of spin-offs, in addition to the tax burdens on all parties involved in the corporate restructuring, which parallels the work of Scholes et al. (2008). This study provides implications that various aspects should be considered and reviewed in advance when the management makes decisions for effective tax planning.

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Physicochemical and sensory properties of Yakhobak (Cucurbita maxima subsp. maxima) paste under different high pressure heating conditions (가열조건에 따른 약호박(Cucurbita maxima subsp. maxima) 페이스트의 이화학적 관능적 품질특성)

  • Park, Bo-Ram;Choi, Su-Jeong;Kim, Na-Jeong;Han, Gui-Jung;Kim, Ha-Yun
    • Food Science and Preservation
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    • v.24 no.1
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    • pp.44-51
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    • 2017
  • For the production of Yakhobak (Cucurbita maxima subsp. maxima) paste under various heating conditions, we steamed Yakhobak for roughly 20 min, followed by heating under high pressure treatment for 0 min (HHP0), 20 min (HHP20), 40 min (HHP40), and 60 min (HHP60). The physicochemical and sensory characteristics were subsequently investigated. Generally, no significant difference was observed in organic acid content and sensory characteristics score between Yakhobak paste treated with and without high-pressure heating. However, there was a significant difference in color value, soluble solids, and free sugar content. The L value for color of the group HHP0, untreated control Yakhobak paste (no high-pressure heating), decreased as time increased from 20 min to 60 min, with L values of 44.33, 44.25, and 42.86, respectively. The b value for the color of Yakhobak paste also decreased, showing a significant difference. Soluble solids and free sugar (fructose, glucose, sucrose) contents of the high-pressure heat-treated groups HHP20, HHP40, and HHP60 decreased compared with untreated group HHP0. Organic acid composition of Yakhobak paste included citric acid, malic acid, and fumaric acid, and the major organic acid was malic acid. Sensory score of HHP40 was the highest among all experimental groups in terms of overall preference, but there was no significant difference.

Changes of Ginsenosides and Physiochemical Properties in Ginseng by New 9 Repetitive Steaming and Drying Process (새로운 자동 구증구포방법에 의한 인삼사포닌의 변환 및 이화학적 특성)

  • Jin, Yan;Kim, Yeon-Ju;Jeon, Ji-Na;Wang, Chao;Min, Jin-Woo;Jung, Sun-Young;Yang, Deok-Chun
    • Korean Journal of Plant Resources
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    • v.25 no.4
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    • pp.473-481
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    • 2012
  • This study was conducted to investigate the contents of ginsenosides and physiochemical properties of Panax ginseng after 9 times steaming and drying treatment by using the new auto steamer which is more fast and simple than previous report. In the process of steaming and drying, the content of six major ginsenosides such as Rg1, Re, Rb1, Rc, Rb2 and Rd were gradually decreased. On the other hand, the content of seven minor ginsenosides includes Rh1, 20(S)-Rg2, 20(R)-Rg2, 20(S)-Rg3, 20(R)-Rg3, Rk1 and Rg5 were gradually increased. We observed the protopanxadiol ginsenosides such as Rb1, Rb2, Rc and Rd were converted into 20(S)-Rg3, 20(R)-Rg3, Rk1 and Rg5; similarly protopanxatriol ginsenosides of Rg1 and Re were converted into Rh1, 20(S)-Rg2 and 20(R)-Rg2. Based on the result of fresh ginseng, the contents of reducing sugar, acidic polysaccharide and total phenolic compounds were gradually increased and reached to maximum at 7 times repetitive steaming process of the fresh ginseng. Whereas DPPH radical scavenging activities were gradually decreased to 68% at 7 times steaming. New auto 9 repetitive steaming and drying process has similar production with original methods, but content of benzo(a)pyrene were not almost detected comparatively taking less time. The present results suggested that this method is best for the development of value-added ginseng industry related products.

Effect of Sugars on the Bacterial Spoilage of Ground Meat (당류(糖類)의 첨가(添加)가 육(肉)의 세균성(細菌性) 부패(腐敗)에 미치는 영향(影響))

  • Kim, Oun-Hyun;Kim, Chang-Han
    • Korean Journal of Food Science and Technology
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    • v.11 no.4
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    • pp.217-223
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    • 1979
  • The present study was to investigate the effect of sugars on the psychrophillic spoilage in ground meat. The obtained results were summarized as follows: 1. The minimum pH values for the ground beef containing 2, 5 and 10 % glucose were 5.25, 5.15 and 4.5, respectively. For the ground pork, the respective values were 5.1, 4.45 and 4.1. 2. Total aerobes, coliform, lactic acid bacteria and lactobacillus counts per gram for the control and 2% glucose-contained ground beef after 9 days for storage at $5^{\circ}C$ were $8.3{\times}10^9vs\;6.0{\times}10^7,\;3.5{\times}10^5vs\;2.4{\times}10^3,\;5.8{\times}10^7vs\;4.7{\times}10^6$ and $3.6{\times}10^5vs\;4.2{\times}10^6$ respectively. For the ground pork, the respective values were $1.2{\times}10^{10}vs\;7.8{\times}10^8,\;3.4{\times}10^5vs\;3.1{\times}10^4,\;5.5{\times}10^7vs\;4.5{\times}10^6$ and $3.3{\times}10^5vs\;3.7{\times}10^5$. The glucose-added ground meat showed higher counts than those of the controls only in the case of lactobacillus without any apparent adverse effects. 3. The length of storage time until the depletion of added glucose was 12, 16 and 28 days for the 2, 5 and 10 % glucose contained ground beef and 9, 16 and 30 days for the ground pork, respectively. pH did not start to increase until the added glucose was depleted completely. 4. The addition of glucose extended significantly the average shelf-life of ground beef at refrigeration condition $(5^{\circ}C)$. The extended shelf-life over the control was 7, 9 and 12days for the 2, 5 and 10 % glucose contained ground beef and 8, 10 and 12 days for the respective ground porks. 5. Although the addition of disaccharides (maltose, lactose, saccharose) lowered the pH of ground meat, the extension of shelf-life as seen in glucose treatment was not affected. In fact, the higher the concentration of added disaccharides was, the greater the degree of putrefaction occurred.

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Trial for Drug Susceptibility Testing of Mycobacterium tuberculosis with Live and Dead Cell Differentiation (세포 염색 방법을 이용한 결핵균 감수성 검사법)

  • Ryu, Sung-Weon;Kim, Hyun-Ho;Bang, Mun-Nam;Park, Young-Kil;Park, Sue-Nie;Shim, Young-Soo;Kang, Seongman;Bai, Gill-Han
    • Tuberculosis and Respiratory Diseases
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    • v.56 no.3
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    • pp.261-268
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    • 2004
  • Background : The resurgence of tuberculosis and outbreaks of multidrug resistant (MDR) tuberculosis have increased the emphasis for the development of new susceptibility testing of the Mycobacterium tuberculosis for the effective treatment and control of the disease. Conventional drug susceptibility testings, such as those using egg-based or agar-based media have some limits, such as the time required and difficulties in determining critical inhibitory concentrations, but these are still being used in many diagnostic laboratories because of no better lternatives, considering cost and accuracy. To overcome these limits, a rapid and simple method for new susceptibility testing, using live and dead assays, was applied for a bacterial cell viability assay to distinguish dead from live bacterial cells based on two-color fluorescence. Materials and Methods Strains : Forty strains were used in this study, 20 susceptible to all antituberculosis drugs and the other 20 resistant to the four first line antituberculosis drugs isoniazid, rifampicin, streptomycin and ethambutol. Antibiotics : The four antibiotics were dissolved in 7H9 broth to make the following solutions: $0.1{\mu}g\;isoniazid(INH)/m{\ell}$, $0.4{\mu}g\;rifampicin(RMP)/m{\ell}$, $4.0{\mu}g\;streptomycin(SM)/m{\ell}$ and $4.0{\mu}g\;ethambutol(EMB)/m{\ell}$. Results : Live and dead Mycobacterium tuberculosis cells fluoresced green and red with the acridin (Syto 9) and propidium treatments, respectively. These results are very well accorded with conventional drug susceptibility testing by proportional method on Lowensen-Jensen media (L-J) containing 4 drugs (INH, RMP, EMB and SM), showing a 93.7 % accordance rate in susceptible strains and 95% in resistant strains. Conclusion : The results of the drug susceptibility testing using the live and dead bacterial cell assay showed high accordance rates compared with the conventional proportion method on L-J. This finding suggests that the live and dead bacterial cell assay can be used as an alternative to conventional drug susceptibility testing for M. tuberculosis strains.

Glomus Tumor in Soft Tissue (연부 조직에 발생한 사구종)

  • Kim, Do-Yeon;Lee, Soo-Hyun;Kim, Min-Ju;Shin, Kyoo-Ho
    • The Journal of the Korean bone and joint tumor society
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    • v.15 no.1
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    • pp.34-43
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    • 2009
  • Purpose: Glomus tumors are rare benign vascular tumors, usually located in the skin or soft tissue of extremities. Approximately 30-50% of glomus tumors occur in subungal area, but glomus tumors have been described in every location even where glomus bodies are not or rarely present. The purpose of this study was to identify clinical, histologic and MRI characteristics of soft tissue glomus tumor. Materials and Methods: Between 1993 and 2008, eight patients underwent surgery of soft tissue Glomus tumor at our institution. Exclusion criteria were patients with Glomus tumors in digits, stomach, trachea and glomus tympanicum. We analyzed medical records, interviews, physical examinations, MR findings and histolocial types retrospectively. Results: There were four men and four women. The mean age was fourty-seven years. The mean prevalence time was eight-point-nine years. In the classic triad of symptoms, all eight patients had pain and tenderness. Two patients complained of cold sensitivity. Two showed skin color changes. After surgery, two showed symptom improvement (VAS $9^{\circ}{\rightarrow}8$, $8^{\circ}{\rightarrow}5$) and?six showed complete disappearance of symptoms. Slightly symptom improvemented (VAS $9^{\circ}{\rightarrow}8$) one had additional surgery two times after first surgery due to relapse/remaining Glomus tumor. The mean size was 13.9 mm. In histology, six were 'solid glomus tumor', one was a mixture of 'solid glomus tumor' and 'lomangioma' and one was 'malignant glomus tumor'. MR findings showed isointense signal on T1 image, high signal on T2 image and strong enhancement on the Gadolinium enhanced image. Conclusion: Glomus tumor has low recurrence rate and malignant change, rapid diagnosis and surgical excision is critical in treatment to prevent unnecessary pain of patient.

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Assessments of Negotiation Options Regarding Post-2012 Rules for Land Use, Land-Use Change and Forestry (LULUCF) -With a Focus on the Forest Management Activities under the Kyoto Protocol - (Post-2012 LULUCF 협상 대안 평가 -산림경영 활동을 중심으로 -)

  • Bae, Jae-Soo
    • Journal of Korean Society of Forest Science
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    • v.98 no.1
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    • pp.55-65
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    • 2009
  • Annex I parties continued its consideration of how to address, the definitions, modalities, rules and guidelines for the treatment of Land Use, Land-use Change and Forestry (LULUCF) in the second commitment period of the Kyoto Protocol by the year of 2009. In the AWG-KP conference held in Accra, Ghana in 2008, four alternatives (gross-net carbon accounting, net-net with base year or base period accounting, net-net with forward looking baseline accounting, and land-based accounting method) for negotiations were decided in order to revise gross-net accounting method applied during the first commitment period of the Kyoto Protocol. In this study, alternative scenarios are set in consideration with reporting system (voluntary or compulsory), discount factors and cap about these three alternatives except for the method of net-net with forward looking baseline accounting, and then estimates the Removal Unit (RMU) among the countries. In the case that article 3.4 activities under the Kyoto Protocol revises from voluntary reporting to mandatory reporting, it is estimated that the loss of RMU would be huge in Russia, Australia, New Zealand, as well as Canada potentially. Net-net with base year or base period carbon accounting and land-based carbon accounting method have big difference of RMU in accordance with the base year or the base period. So the more unfavorable the country with a lot of old-age forests was, the closer the base year or period comes to the commitment period in the context of RMU. If it is getting lowered for the current rate of 85% in discount factors, RMU is getting higher to the whole countries. Therefore in Korea with little potential for afforestation and reforestation, there was the most sensitive response to the change of discount factors. Post-2012 LULUCF hereafter, it is strongly expected for the succession of current carbon accounting system which is voluntary reporting of gross-net carbon accounting and the activity for article 3.4. Other carbon accounting method is hard to accept in aspect that there is big differentiated interests among the countries and it is required enormous cost and time to develop reliable method. Provide for Post-2012 mandatory greenhouse gas reduction, Korea needs to have a competitive negotiation strategies differentiated from Annex I countries. The most reliable alternative would be to lower the discounting factors about the activities for forest management.

Sleep Patterns of Pregnant Women (임부의 수면양상)

  • Choi, Byeung-Sun;Yoon, Jin-Sang
    • Sleep Medicine and Psychophysiology
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    • v.5 no.1
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    • pp.45-53
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    • 1998
  • Objectives : The change of sleep patterns commonly occurs in association with the pregnancy. This study was to investigate sleep habits during the course of normal pregnancy. Methods : Sleep habits questionnaire was administered to healthy women in their first trimester(TR1) of pregnancy and then the same questionnaire was repeatedly administered during their second(TR2) and third(TR3) trimesters. The following aspects were assessed : patterns of night sleep, daytime status, sleep posture, reasons for sleep alteration, and the experience of any particular parasomnias, as well as sleep problem-related treatment or medication. Data analysis was based on 26 women who maintaind good health throughout their pregnancy and completed the questionnaire three times. Results : In comparisons between each trimester and non-pregnant state, total night sleep time, daytime tiredness, and sleepiness were significantly increased in all trimesters. Sleep latency was significantly decreased in TR1 and TR2, but not in TR3. In addition, refreshed feeling on waking the following day was significantly decreased and the number of awakenings during night sleep was significantly increased in TR3, but not in TR1 and TR2. In comparisons between trimesters, there was a significant increase in sleep latency, daytime sleepiness and the number of awakenings during night sleep and a significant decrease in refreshed feeling on waking the following day in TR3 compared to TR1 and TR2. Over the course of pregnancy, the rate of lateral position during sleep was gradually increased and all the pregnant women took the lateral sleeping posture in TR3. The major reasons for sleep pattern alteration were nausea, vomiting and heartburn in TR1, urinary frequency, fetal movement and ache in hips in TR2, and urinary frequency, fetal movement, cramp in legs and backache in TR3. Conclusion : These findings are expected to be useful for educating pregnant women about sleep hygiene. In future studies, the underlying factors and mechanisms regarding sleep patterns during pregnancy will need to be clarified.

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The evaluation of clinical efficacy and longevity of home bleaching without combined application of In-office bleaching (자가미백술 단독사용시 임상적 효능 및 유지력 평가)

  • Shin, Byunk-Gyu;Yang, Sung-Eun
    • Restorative Dentistry and Endodontics
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    • v.35 no.5
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    • pp.387-394
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    • 2010
  • Objectives: The purpose of this study was to evaluate the whitening efficacy and longevity of home bleaching. Materials and Methods: A total of 28 patients were divided into either experimental group (Opalescence F; 15% carbamide peroxide) or control group randomly. The patients in experimental group were instructed to wear individual trays applied with bleaching gel for 2 hours a day for 4 weeks. Any treatments weren't applied to the patients in control group. The color measurements of central incisors, lateral incisors & canines of upper and lower arch were recorded at base line, immediately after the finishment of treatmemt (4 weeks), 8 weeks and 12 weeks using Colorimeter (Chroma Meter, 2600d Konica Minolta co.) and Vitapan classical shade guide (Vita Zahnfabrik). Results: A significantly stronger color change was observed for overall teeth samples in experimental group immediately after treatment (at 4 weeks) compared to ones in control group (p < 0.05). There was also a significant difference between baseline and 8 weeks or 12 weeks separately though color rebouncing phenomenon occurred as time went by (p < 0.05). Conclusions: The clinical effecacy and longevity of home bleaching without combined application of in-office bleaching was observed through this experiment.

Quality Characteristics of Yulmoo Mul-kimchi Containing Saltwort (Salicornia herbacea L.) (함초 분말 첨가 열무 물김치의 품질특성)

  • Park, Jung-Eun;Lee, Jae-Yong;Jang, Myung-Sook
    • Journal of the Korean Society of Food Science and Nutrition
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    • v.40 no.7
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    • pp.1006-1016
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    • 2011
  • Saltwort (Salicornia herbacea L.), as a natural additive for regulating Mul-kimchi fermentation, was assessed for physicochemical and sensory characteristics of Yulmoo Mul-kimchi during storage. Saltwort in the form powder was directly added to the Yulmoo Mul-kimchi preparation at 0 (control), 1, 3, 5, and 7% (w/v) per weight of salt to evaluate their physicochemical, sensory, and microbiological characteristics in storage at $10^{\circ}C$ for 30 days. The pH values of all treatments were high, indicating a less acidic environment in all treatments compared to those of the control sample throughout the preservation period. Total acidity increased with storage time as is usually seen with normal kimchi fermentations, whereas the increases were more gradual in the 3 and 5% treatments. The increases in total vitamin C continued until days 6 (control) to 13 (7%), and were different according to the amount of added saltwort and then they decreased after each peak. The fluctuation in reducing sugars fol owed a similar trends of total vitamin C content by showing an initial increase, followed by a decrease based on the saltwort concentration and storage day. The 5% treatment was most effective for suppressing the increase in turbidity among all treatments. The 3 and 5% treatments showed the highest lactic acid bacteria counts during the entire preservation period. In the sensory evaluation results, adding saltwort at more than 3% concentration attained an overall higher scores of acceptability with respect to color, smell, taste, fresh taste, sour taste, crisp, and overall acceptability characteristics. In conclusion, adding saltwort, particularly at concentrations of 3 and 5% extended the preservation period of Yulmoo Mul-kimchi by retarding fermentation effectively.